ML20206J316

Notice of Nonconformance from Insp on 860512-16

ML20206J316
Person / Time
Issue date:	06/25/1986
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE)
To:
Shared Package
ML20206J281	List: ML20206J278 ML20206J297 ML20206J316 ML20206J327
References
REF-QA-99901055 99901055-86-01, 99901055-86-1, NUDOCS 8606270088
Download: ML20206J316 (5)

Text

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APPENDIX B WFI Nuclear Products, Inc.

Houston, Texas .

NOTICE OF NONCOMFORMANCE Based on the results of an NRC inspection conducted on May 12-16,1986, i t appears that certain of your activities were not conducted in accordance with NRC requirements.

Criterion V of Appendix B to 10 CFR Part 50 states: " Activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings. Instructions, procedures, or drawings shall include appropriate quantitative or qualitative acceptance. criteria for determining that important activities have been satisfactorily accomplished."

Nonconformances with these requirements are as follows:

A. Section 4.2.3 of the Nuclear Quality Assurance Manual (NQAM dated November 9, 1983 states, in part: "The document [ procedure _ shall be written by a qualified person. . . ."

Section 7.3.2 of the NQAM states, "The examination procedures shall be prepared and approved by the Level III Examiner."

Subsection NCA-3864.2 of Section III of the ASME Code requires that all personnel performing activities within the scope of Section III be qualified.

Contrary to the above, it was noted that the QA Manager had written two NDE procedures (i.e., UT-2-84, " Ultrasonic Examination for Forged Material" and LP-1-84, " Visible Dye Liquid Penetrant Examination Procedure") in September 1984, but there was no documented evidence that the individual was qualified to be a level III Examiner.

(86-01-02)

8. Section 7.2.1 of the NQAM requires that NDE personnel be certified in accordance with WFI's written practice which meets the requirements of SNT-TC-1A.

Section 8.7.5 of Procedure No. AD-3, " Written Practice - SNT-TC-1A",

dated April 1986, and Section 9.6.1 of SNT-TC-1A require that the qualification records of certified individuals include a statement indicating satisfactory completion of training in accordance with WFI's written practice.

8606270088 860625 PDR GA999 EMVWFINP 99901055 PDR

[ . .

e Contrary to the above, the qualification records of WFI's Level III Examiner did not contain a statement that the individual met the training requirements of Procedure No. AD-3. (86-01-03)

C. Section 4.1 of Procedure No. WFI-22, dated September 12, 1984 states, in part:

... inspectors shall use only calibrated plug gages, micrometers, thread gages, scales, and calipers, and other inspection equipment. . . ."

Contrary to the above, a non-calibrated protractor / scale (S/N S2) was used to measure the linear dimensions of a fitting supplied on P0 No. N-2473. (86-01-04)

D. Section 9.2.8 of the NQAM states, in part: " ... temperature instru-mentation used to control test temperature of-[Charpy] specimens shall be calibrated at least once every 3 months...."

Contrary to the above, the digital temperature display (S/N 99689) for the Charpy impact test bath was 2 months late in its calibra-tion schedule. In addition, 2 certifications of calibration were missing from the files for May 8 and August 8, 1985. (86-01-05)

E. Section 9.2.7 of the NQAM states, in part: "

. . .thermocouples shall be calibrated and used at all times during heat treat operations...."

Subsection NCA-3868.1 of Section III of the ASME Code, states, in part:

...a procedure shall be in effect to assure that tools, gages, instruments, and other measuring and testing devices...are calibrated and properly adjusted...."

Contrary to the above, WFI did not have a procedure for the calibration of thermocouples used in the heat treat furnaces.

(86-01-06)

F. Section 11.4.1 of the NQAM states, in part: "WFI Nuclear Products.

Inc. Certified Material Test Report shall consist of...the following:

(1) Actual results of chemical analysis...(2) Actual results of mechanical tests...(4) Heat treatment (specific times and tempera-tures)...."

Subsection NCA 3867.4(a) of Section III of the ASME Code requires that Certified Material Test Reports (CMTR) include the actual result of all required chemical analyses and tests and specific times and temperatures of heat treatments.

Contrary to the above, it was noted: (86-01-07)

1. WFI CMTRs did not agree with Southwestern Laboratory Reports on a number of chemical elements for heat codes 305 BN, 209 BN, 219 BN, and 976 AN on nuclear orders N-2516, -2437, -2298, and

-2476, respectively.

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2. Heat treat statement on CMTR did not agree with time / temperature chart, dated February 13, 1986, for heat code 222 BN on nuclear orders N-2376 and N-2496.

3. Supporting documentation (i.e., test report and time / temperature chart) was missing to substantiate the mechanical properties and heat treat statement on the CMTR, dated May 9,1986, for heat code 134~BN on nuclear order N-2641,

4. On nuclear order N-2231, for item 1 (heat code 270 BN),

a time / temperature chart did not exist to substantiate the heat treat statement on the CMTR, dated October 31, 1985; and for item 2 (heat code 226 BN), a test report did not exist to substantiate the mechanical properties and the heat treat statement did not agree with the time / temperature chart, dated October 10, 1985.

G. Section 8.2.3 of the NQAM states, in part: "The Nonconformance and Disposition Report number will be noted on the Nuclear Travel and/or' material process record at the operation the discrepancy is discovered at."

Section 8.2.6 states, in part: "The WFI Nuclear Products, Inc.

Quality Assurance Manager shall convene a Material Review Board consisting of the following individuals: (1) Quality Assurance Manager... (2) Engineering Manager... (3) Purchasing Manager...

(4) Production Manager... (for in-process nonconformances), *

(5) Additional personnel as required...."

Section 8.4.2 states, in part: "It is the responsibility of the QA Manager to see that the corrective action is initiated and followed through."

Section 8.4.4 states, in part: " Management shall receive an annual summary of all NDR's (Nonconformance and Disposition Report)...."

Contrary to the above, during a review of 39 NDRs, three Nuclear Travelers, and the NDR log book, it was noted: (86-01-08)

1. Nuclear Traveler Nos. N-2602, N-2435, and N-2555 did not identify the NDR number for the nonconformance generated.

2. NDR Nos. 0038 and 0039 were dispositioned by a Material Review Board consisting of only the President, QA Manager, and Vice President of Technical Services.

3. Documented evidence was missing to show that the QA Manager had verified corrective action was initiated for NDR Nos. 0001 through 0015.

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4. Documented evidence was missing to show that an annual summary of all NDRs was reviewed by management.

H. Section 12.2.1 of the NQAM states, in part: " Internal audits shall be conducted a minimum of once every 12 months...shall consist of a detailed audit of all aspects of the program for compliance with this... Quality Assurance Manual."

Section 12.2.4 states, in part: " Copies of the Audit Summary Report and checklist shall be sent to Management and all managers of departments that were audited."

Section 12.2.6 states, in part: "After the corrective action implementation has been completed the audit team shall conduct a follow-up audit to verify... follow-up audit reports shall be issued to... Management and managers of departments that were audited."

Contrary to the above, during a review of 13 internal audit reports conducted from January 1981 to January 1986, it was noted: (86-01-09)

1. Documented evidence was missing for audits conducted between December 1983 and December 1985. For those audits conducted from January 1981 to November 1983, QC procedures AD-1 through AD-9 were not included in the audit.

2. The following audits were conducted without any evidence of audit reports being reviewed by management other than the manager of the department that was audited:

Department Audited Date Sales 11/83 and 1/82 Engineering 11/83 and 1/81 Production 11/83 and 1/82 Purchasing 11/83, 1/82, and 1/81 QA 4/83, 1/82, and 6/81

3. There was no documented evidence of follow-up action to verify that corrective action was implemented for the following audits:

Department Audited Date QA 6/22/81 and 4/19/83 Sales 1/26/82

1. Section 3.2.1 of the NQAM states, in part: " Prior to issuance of a ,

purchase order to a vendor, such as a material manufacturer... test laboratory or NDE laboratory, the vendor must be on the Approved Vendor List."

9 Section 3.2.2 states, in part: ... vendors utilized for qualified material shall be placed on the Approved Vendor List after acceptance of vendor survey and audit...."

'Section 3.2.5 states, in part: "The Quality Assurance Department is responsible for issuing the Approved Vendor List...and maintaining a distribution list of this issuance.

Section 3.3.1 states, in part: " Vendors on the Approved Vendor List

shall be periodically audited at least every twelve (12) months...."

Contrary to the above, during a review of four Approved Vendor Lists (AVL) issued from November 1983 to April 1986, 15 vendor audit reports, and four P0s, it was noted: (86-01-10) i 1. Twelve P0s(N-1273, -1171, -1181, -1177, -1163, -1298, -1204, l

-1209, -1261, -1295, -1175, and -1249) were placed with vendors who were not on the AVL, and documented evidence of an audit or i

survey was missing.

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2. A distribution list was missing for AVLs issued by the QA

Department.

3. Thermotemp Instruments was listed on the AVL dated April 1986, but the last audit was in January 1985.

J. P0s N-1209 (July 2, 1985) and N-1204 (June 5, 1985) to K.0. Forge and N-1168(February 22, 1984) and N-1160 (December 1, 1983) to Laclede referenced that forging activities were to be witnessed by WFI QA personnel.

I Contrary to the above, there was no documented evidence presented to the inspector to verify that any WFI personnel witnessed the forging activities at K.0. Forge and Laclede for the material on these four P0s. (86-01-11) )

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